Waste & Recycling

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Don't tread on consumers

On September 15, 2004, Waste Diversion Ontario (WDO) approved the Scrap Tire Diversion Program Plan developed by Tire Stewardship Ontario (TSO). WDO then forwarded the plan to the province's environme...


On September 15, 2004, Waste Diversion Ontario (WDO) approved the Scrap Tire Diversion Program Plan developed by Tire Stewardship Ontario (TSO). WDO then forwarded the plan to the province’s environment minister for posting on the Environmental Bill of Rights Registry and for public comment. To date, the minister has not approved the TSO plan.

The TSO plan was initially developed in response to a March 2003 request for a scrap-tire program by then-Minister of Environment Chris Stockwell. Despite the minister’s request that brand-owners and first importers be designated as program “stewards,” WDO recommended to the minister that the program obligations be transferred to tire retailers.

This fundamental shift away from “producer” responsibility set the stage for TSO to develop a program that requires retailers to remit a $4.00 and $6.00 Tire Stewardship Fee respectively for each passenger and light truck tire sold (which will inevitably be passed on to consumers as point-of-sale fee). Controversially, a component of the TSO plan is to direct a significant portion of the pooled levies to promote the burning of tires in cement kilns and to do so in a manner that economically favors burning of tires over their recycling into products such as rubberized asphalt, roofing shingles, automotive components, and other products.

As a working alternative to the TSO plan, the Ontario Tire Dealers Association (OTDA) — an industry association representing approximately 650 independent tire retailers who sell more than 60 per cent of tires sold in the province annually — and the Ontario Tire Collectors Association (OTCA), commissioned the development of OnTRED — the Ontario Tire Recycling and Economic Development plan, which is focused on meeting the following key criteria:

* Be environmentally effective by promoting reuse and recycling, consistent with provisions of the Waste Diversion Act;

* Be economically efficient through a minimalist approach to regulation that enhances rather than disrupts the existing workings of the tire and scrap tire market;

* Minimize administration and compliance costs;

* Generate fewest unintended effects on competition, consumer prices, trade patterns, etc.;

* Maximize communication and education to tire consumers; and

* Be dynamic and drive innovation and economic development in tire reuse and recycling.

OnTRED has four basic mechanisms that allow it to meet these criteria.

The first is a system of consumer-based “buy recycled” rebates similar to those provided for the purchase of energy-efficient appliances. This proven approach, of using economic instruments to drive demand and market development, operates by setting consumer rebates based on the percentage recycled rubber content in a product and the relative value of that product. As an example, under OnTRED municipalities that purchase rubberized asphalt pavement could receive a rebate of about $621 per km of a paved lane road.

The second component is a system for registering tire collectors and tracking the disposition of collected scrap tires in order to prevent tire stockpiles.

TSO estimates that tire recovery Ontario is currently about 87 per cent. Some of the un-recovered scrap tires inevitably end up in stockpiles. Tire stockpiles occur because some retailers award their scrap tires to tire collectors solely on cost. In some cases collectors without a legitimate destination for tires can charge below-market prices for tire collection. The result is tire stockpiles.

Under OnTRED, scrap tire generators would only be able to enter into commercial agreements for scrap tire pick-up with environment ministry-accredited collectors. In turn, collectors would be required to have a commercial arrangement with a legitimate receiver of scrap tires and to be able to make the details of collector/generator transactions (pick-up, transport and deliveries) available for ministry verification. A similar system of assigning and tracking liability for waste has proven extremely successful in Ontario for hazardous waste and is largely responsible for the province’s 78 per cent recovery rate for used motor oil — the rate highest in Canada.

The third component of OnTRED is a stockpile inventory, moratorium and remediation program. OnTRED proposes an immediate landfill ban on tires, and an inventory of private and public tire piles in Ontario. With regard to private stockpiles (and consistent with the polluter pays principle) landowners with existing tire piles would be required to clean up their properties under the Environmental Protection Act. OnTRED also proposes a contingency fund to be used only when the government is unsuccessful in forcing landowners to pay or are unable to fully cover stockpile cleanup through property value.

As for public tire stockpiles, the Association of Municipalities of Ontario (AMO) is currently determining the size and location of scrap tire piles in Ontario. This information will be used to determine which tire piles require immediate remediation. OnTRED will offer municipalities a one-time subsidy to help finance remediation. The subsidy level can only be determined once the inventory is complete as subsidies will depend on the size and location of the piles.

The last component of the plan is its source of funding. Consistent with the principles of Extended Producer Responsibility and the original intent of the program, funds used for rebates, market development, R&D, collector registration, program monitoring and administration are to be provided by brand owners and first importers of tires.

OnTRED sets a clear example of how simple, unobtrusive market “interventions” can protect the environment without running over consumers.

Glenn Warnica is president of the Ontario Tire Dealers Association, based in Burlington, Ontario. Contact Glenn at gwarnica@sympatico.ca


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